Did they inform the consumer at the point of purchase that their data would be used in that way, and give them the opportunity to opt out at the time?
Peter Dinsdale
Data Protection Consultant
Perfect Image /
T: 0191 238 0111
www.perfect-image.co.uk
Follow us on Twitter http://twitter.com/perfectimage
-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Duncan Smith
Sent: 23 May 2018 19:33
To: [log in to unmask]
Subject: [data-protection] Facebook custom audience and soft opt-in
One for the digital marketers.
When you create a FB custom audience, it's pretty clear you are directing marketing to a data subject, hence lawful processing would be consent. FB requires you to warrant that you have appropriate consent to upload the email address by ticking a box.
Can I use the current PECR (22) soft opt-in as consent? Would SM message be the same as an email or text?
Scenario to help. Consumer buys product from eCommerce site. Marketer would like to upsell. Targets a message to customer's Facebook account with 20% off voucher for next purchase. Legal are happy that valid soft opt-in has been acquired.
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